READING GLUTEN-FREE LABELS ABROAD Source check: 1 November 2026. AU/NZ: Schedule 4 C07, 30 April 2026. Original record and fictional exercises, not product or medical approval. PACKAGE RECORD 1 Market and product: Facts: ______________________ Question: ______________________ Exact claim: Facts: ______________________ Question: ______________________ Full ingredients and declarations: Facts: ______________________ Question: ______________________ Evidence and next question: Facts: ______________________ Question: ______________________ PACKAGE RECORD 2 Market and product: Facts: ______________________ Question: ______________________ Exact claim: Facts: ______________________ Question: ______________________ Full ingredients and declarations: Facts: ______________________ Question: ______________________ Evidence and next question: Facts: ______________________ Question: ______________________ CLAIM COMPARISON United States: FDA-regulated packaged foods | Less than 20 ppm, together with ingredient restrictions. | The FDA gluten-free rule does not establish a separate equivalent “low gluten” category. | Oats may carry the claim if they meet the rule; a particular certification is not required by FDA. European Union: Regulation 828/2014 | No more than 20 mg/kg in the food as sold to the final consumer. | Very low gluten: no more than 100 mg/kg, with qualifying specially processed cereal ingredients. | Oats must be specially produced, prepared and/or processed to avoid specified cereal contamination and cannot exceed 20 mg/kg. Great Britain: UK-published Regulation 828/2014 | The reviewed Annex states no more than 20 mg/kg. | The reviewed Annex uses the same 100 mg/kg and specially processed ingredient conditions. | The reviewed Annex includes the additional oat production and 20 mg/kg conditions. Northern Ireland: check the applicable supply arrangements | Do not infer the regime from “UK” or “made in Britain” alone. | FSA explains that specified prepacked retail goods moved under NIRMS can use GB standards. | Identify the applicable product and supply route; the general country name alone is insufficient. Australia and New Zealand: Schedule 4, C07, 30 April 2026 | No detectable gluten; no oats or oat products; no malted gluten-containing cereals or their products. | Low gluten: no more than 20 mg gluten per 100 g of food. This is not the EU “very low gluten” category. | The gluten-free claim excludes oats/oat products; do not transfer an overseas gluten-free oat claim unchanged. UNIT REMINDER 1 ppm by mass = 1 mg/kg; 20 mg/100 g = 200 mg/kg. No detectable gluten is not a universal numerical detection limit. FDA: less than 20 ppm plus ingredient conditions; EU/UK Annex: no more than 20 mg/kg. EIGHT FICTIONAL PRACTICE CASES Case 1: A fictional US FDA-regulated food lists intentionally added barley malt. A seller says its result is 12 ppm and therefore the gluten-free claim must comply. Is the number enough? Your answer and reason: ______________________ Case 2: A fictional EU food contains qualifying specially processed cereal ingredients and is described as 60 mg/kg gluten. Does that number support calling it gluten-free? Your answer and reason: ______________________ Case 3: A fictional result is exactly 20 mg/kg. May you say that the US and EU concentration wording is identical at that boundary? Your answer and reason: ______________________ Case 4: A fictional Australian label says low gluten. Someone equates its 20 mg/100 g limit with the EU 20 mg/kg gluten-free limit. What needs correcting? Your answer and reason: ______________________ Case 5: An oat snack bought in the US carries a gluten-free claim. Does that prove an identical claim is permitted when that oat-containing food is sold under the Australian/New Zealand Code? Your answer and reason: ______________________ Case 6: A fictional EU food carries a gluten-free claim and lists specially processed wheat starch. Does the word wheat alone prove the claim is contradictory or that the food is wheat-free? Your answer and reason: ______________________ Case 7: A package sold in Northern Ireland says made in Great Britain. Is that phrase enough to identify the labelling regime that applies to this product? Your answer and reason: ______________________ Case 8: A translation app finds no word for wheat in a cropped ingredient photo, while the actual package’s other panels are unread. Has the whole gluten question been checked? Your answer and reason: ______________________ ANSWERS AND EXPLANATIONS Case 1: No. The ingredient restriction still applies. FDA does not allow barley malt in a food bearing a gluten-free claim merely because a finished-food result is below 20 ppm. Save the exact claim and ingredient wording and resolve the contradiction for that product. The concentration is one part of the rule; it does not override a prohibited ingredient. Case 2: No. It exceeds the 20 mg/kg gluten-free limit. The 100 mg/kg very-low-gluten category has different conditions, including the qualifying specially processed ingredients. The stated facts illustrate why the two claims are separate. They do not assess the food for an individual diet or verify a real manufacturer’s compliance. Case 3: No. FDA says less than 20 ppm; the EU Annex says no more than 20 mg/kg. For concentration by mass, ppm and mg/kg describe the same unit. The boundary words differ. This is a reading exercise, not an instruction to approve a food from one laboratory number; sampling, measurement, ingredients and the rest of the applicable requirements still need their own evidence. Case 4: The units and the claim: 20 mg/100 g equals 200 mg/kg. One kilogram contains ten lots of 100 g, so the first concentration is ten times 20 mg/kg. Schedule 4 uses this number for low gluten, while its gluten-free conditions require no detectable gluten and exclude specified ingredients. Neither claim should be silently renamed as the other. Case 5: No. The claim rules for oats differ. FDA allows oats to carry the claim when its requirements are met; the reviewed Australia/New Zealand gluten-free claim excludes oats and oat products. Match the applicable market version rather than treating a foreign claim as universal. Whether oats fit a person’s dietary plan is a separate clinical question. Case 6: Neither conclusion follows from that word alone. The gluten claim concerns the applicable gluten requirements; a wheat-related ingredient and allergen question needs its own reading. The claim does not mean wheat-free or assess a wheat allergy. Read the current complete label and resolve product-specific uncertainty instead of using either a wheat-only rejection rule or an allergy assurance. Case 7: No. Identify the applicable supply arrangements and market information. FSA describes special arrangements for specified prepacked retail goods moved from GB through the Northern Ireland Retail Movement Scheme. A country-of-manufacture phrase does not demonstrate that a particular item used that scheme. Ask the importer or manufacturer for the missing product-specific context instead of inferring it. Case 8: No. The current label and broader ingredient question remain incomplete. Wheat is not the only relevant cereal, the image may omit the claim or other ingredients, and translation can miss context. Read all actual panels and obtain reliable local or manufacturer clarification where needed. An incomplete photograph, shelf position or a lack of immediate symptoms is not a verification method. SOURCE REFERENCES FDA: Questions and Answers on Gluten-Free Food Labelling https://www.fda.gov/food/nutrition-food-labeling-and-critical-foods/questions-and-answers-gluten-free-food-labeling-final-rule EUR-Lex: Regulation (EU) 828/2014 https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32014R0828 UK legislation: Regulation 828/2014 Annex https://www.legislation.gov.uk/eur/2014/828/annexes FSA: Allergen Guidance for Food Businesses https://www.gov.uk/government/publications/allergen-guidance-for-food-businesses/allergen-guidance-for-food-businesses Australia/New Zealand: Official Schedule 4, Compilation C07 https://www.legislation.gov.au/F2015L00474/2026-04-30/2026-04-30/text/original/epub/OEBPS/document_1/document_1.html Coeliac UK: How to Read Food Labels https://www.coeliac.org.uk/living-with-coeliac-disease/food-and-drink/food-and-drink-information/how-to-read-food-labels/